Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
The ITAT upheld the exercise of revisional jurisdiction under s.263 of the I.T. Act, finding the assessing officer's acceptance of claimed long-term capital gains purportedly exempt under s.10(38) to be erroneous and prejudicial to the revenue because he failed to verify crucial transactional particulars - mode of trade, dematerialization and debit/credit entries in the taxpayer's demat account - before allowing exemption on penny-stock transactions. The Tribunal endorsed that s.263 may be invoked even where facts are disclosed or issues are debatable if the AO did not examine them as per law, and consequently dismissed the taxpayer's appeal.
The ITAT upheld the exercise of revisional jurisdiction under s.263 of the I.T. Act, finding the assessing officer's acceptance of claimed long-term capital gains purportedly exempt under s.10(38) to be erroneous and prejudicial to the revenue because he failed to verify crucial transactional particulars - mode of trade, dematerialization and debit/credit entries in the taxpayer's demat account - before allowing exemption on penny-stock transactions. The Tribunal endorsed that s.263 may be invoked even where facts are disclosed or issues are debatable if the AO did not examine them as per law, and consequently dismissed the taxpayer's appeal.
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